On 15 October 2025 the Federal Ministry of Finance published its second letter on the e-invoice, supplementing the introductory letter from October 2024. The points that matter most in practice:
- For the first time, errors are distinguished in three classes – format errors, business-rule errors and content errors – each with different legal consequences for input-tax deduction
- All mandatory details must appear in the structured part of the invoice. References to attachments or accompanying documents are not enough: in legal terms, only what is in the XML counts
- The structured part of the e-invoice must be retained unchanged and traceable for eight years
- On corrections: if only the amount changes (for example through a cash discount or rebate), no new invoice is needed – if the content of the service changes, one is
The consequence for invoice intake: checking the structured part becomes more important. With a hybrid invoice, if you only check the PDF image, you are not checking the invoice.
Please note: this article reflects the legal position and administrative guidance as at the date stated and is no substitute for tax or legal advice.